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Page 1: Michelle_Obama_Spain


Number of Pages:4

Date Created:March 5, 2012

Date Uploaded to the Library:February 20, 2014

Tags:Spain, Michelle, Obama

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  • demand_answers

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Boasberg, James 
425 Third Street, SW, Suite 800  
Washington, D.C. 20024,  
Plaintiff,  -00345 Cas: 1:12-C 
1000 Air Force Pentagon Washington, 20330-1000, 

PlaintiffJudicial Watch, Inc. brings this action against Defendant U.S. Air Force compel 
compliance with the Freedom oflnfonnation Act, U.S.C.  552 ("FOIA"). grounds therefor, 
Plaintiff alleges follows: 
JURISDICTION AND VENUE The Court has jurisdiction over this action pursuant U.S.C.  552(a)(4)(B) and U.S.C.  1331. Venue proper this district pursuant U.S.C.  1391(e). 
PARTIES Plaintiff non-profit, educational foundation organized under the laws the 
District Columbia and having its principal place business 425 Third Street, SW, Suite 800, 
Washington, 20024. Plaintiff seeks promote integrity, transparency, and accountability 
government and fidelity the rule law. furtherance its public interest mission, Plaintiff 
regularly requests access the public records federal, state, and local government agencies, 
entities, and offices, and disseminates its findings the public. 	Defendant agency the U.S. Government and headquartered 1000 Air 
Force Pentagon, Washington, 20330-1000. Defendant has possession, custody, and control records which Plaintiff seeks access. FACTS August 25, 2011, Plaintiff submitted FOIA request Defendant, facsimile 
and certified mail, seeking access the following public records: 
(i) All records concerning mission taskings First Lady 
Michelle Obama's August 2010 trip Spain; 
(ii) 	All records concerning transportation costs for Mrs. 
Obama's August 2010 trip Spain; and 
(iii) 	All passenger manifests (DD-2131) for Mrs. Obama's August 2010 trip Spain. 	According U.S. Postal Service records, the copy the request sent certified 
mail was received Defendant August 30, 2011. 	Pursuant U.S.C.  552(a)(6)(A)(i), Defendant was required determine 
whether comply with Plaintiff's request within twenty (20) working days after receipt the 
request and notify Plaintiff immediately its detennination, the reasons therefor, and the right appeal any adverse determination. Because Plaintiff sent its request the component 
Defendant designated Defendant receive FOIA requests, pursuant U.S.C.  552(a)(6)(A) 
this twenty (20) working day time period did not commence until ten (10) working days after 
Defendant's receipt the request August 30, 2011. Accordingly, Defendant's determination 
was due October 13, 2011 the latest. the date this Complaint, Defendant has failed to: (i) determine whether 
comply with Plaintiff's request; (ii) notify Plaintiff any such determination the reasons 
therefor; (iii) advise Plaintiff the right appeal any adverse determination; (iv) produce the 
requested record otherwise demonstrate that the requested records are exempt from production. Because Defendant failed comply with the time limit set forth U.S.C.  
552(a)(6)(A), Plaintiff deemed have exhausted any and all administrative remedies with 
respect its request, pmsuant U.S.C.  552(a)(6)(C). 
(Violation FOIA, U.S.C.  552) 
Plaintiffrealleges paragraphs through fully stated herein. 

Defendant unlaWfully withholding public records requested Plaintiffpursuant U.S.C.  552. 
12. Plaintiff being irreparably harmed reason Defendant's unlawful 
withholding the requested public records, and Plaintiffwill continue irreparably harmed 
unless Defendant compelled conform its conduct the requirements the law. 
WHEREFORE, Plaintiff respectfully requests that the Court: (1) order Defendant 
conduct search for any and all records responsive Plaintiff's FOIA request and demonstrate 
that employed search methods reasonably likely lead the discovery records responsive 
PlaintifI's FOTA request; (2) order Defendant produce, date certain, any and all non-exempt 
records responsive Plaintiffs FOIA request and Vaughn index any responsive records 
withheld under claim exemption; (3) enjoin Defondant from continuing withhold any and all 
non-exempt records responsive Plaintiff's FOIA request; (4) grant Plaintiff award 
attorneys' fees and other litigation costs reasonably incurred this action pursuant U.S.C.  
552(a)(4)(E); and (5) grant Plaintiff such other relief the Court deems just and proper. 

Dated: March 2012 Respectfully submitted, JUDICIAL WATCH, INC. 

David Rothstein 
D.C. Bar No. 450035 

425 Third Street, S.W., Suite 800 
Washington, 20024 

(202) 646-5172 

Attorneys for Plaintiff